The trial court properly assessed attorney’s fees against plaintiff for filing a frivolous case after dismissing it when plaintiff and her attorney skipped a status conference, and the attorney failed to appear at a later hearing to dismiss the case.

ERISA does not pre-empt a Michigan statute that imposes a one percent tax on health insurance claims paid by insurers or ERISA plan administrators to generate revenue to fund the state’s Medicare obligations.

Where defendant, at the request of a Caucasian patient’s guardian, reassigned a group of African American employees who provided the patient with home care, their federal and state race discrimination claims will be dismissed.

Plaintiff’s attorneys are not liable for unpaid receiver’s fees in this judgment-collection case. The applicable court rule assigns fee responsibility to the party who sought the receiver’s appointment, and attorneys are not “parties” to a case.